Yes, I agree. First classify them as coins and tokens properly and they sub-classify them further. In fact, you have one of the best sub-classifications and one of the reasons that I am particularly interested in your article.

On the other hand, I have to say I disagree with most or all ICO tokens are being securities assertion since most of them pass the Howey Test. There have been several legislative and regulatory initiatives taking place around the world lately regarding the legal status of ICO tokens and ICOs for that matter. For the Guidance published by Singapore’s MAS please check: and for Swiss FINMA’s, check , and I am sure you already heard about US Supreme Court’s the Howey Test. These materials and several articles that I have read convinced me that not all ICO tokens are securities.

For instance, you may purchase a house from a construction company before the construction of the house, which is a pre-sale held by the construction company to fund the construction. Later, you get your house only after it is built. This is not a security sale, at least not in the eyes of Turkish Capital Market’s Board. Just like this, in most ICOs, you fund the team, they build the product and you get your tokens to spend on their platform, etc, which makes them more of a property, than a security. However, some tokens, of course, cannot pass the Howey Test such as the famous “the DAO”.

Finally, I have to admit that I did not conduct a comprehensive analysis on TenX’s PAY but once I have the chance, I will share my opinion.

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